The ICHRA Broker

Guide

Excepted-Benefit HRA (EBHRA), explained

An Excepted-Benefit HRA (EBHRA) is a limited-dollar HRA offered alongside a group plan to cover certain additional benefits — and employees can use it even if they decline the group plan. This guide explains what it is, the annual limit, how it differs from other HRAs, what it reimburses, and who it''s for.

By Joe Rosenblatt · Founder & ICHRA Broker, The ICHRA Broker

Key facts

Offered with
A group health plan
Annual limit
IRS cap (adjusted yearly)
Reimburses
Out-of-pocket + some excepted benefits
Enrollment
Available even if group plan declined

What an EBHRA is

An Excepted-Benefit HRA is a limited-dollar HRA that sits alongside a traditional group health plan. It''s capped at an annual IRS limit (adjusted each year) and reimburses out-of-pocket costs and certain excepted benefits, such as dental, vision, and short-term coverage. It''s a flexible, modest add-on rather than a primary benefit.

The annual limit

EBHRAs are capped at an annual IRS dollar limit that adjusts yearly — a modest amount, much smaller than an uncapped ICHRA. The cap is what keeps it an "excepted benefit" rather than primary coverage. Confirm the current year''s figure, as it changes annually.

How it differs from other HRAs

  • Unlike an ICHRA, it doesn''t reimburse individual major-medical premiums and isn''t a standalone benefit.
  • Unlike a standard GCHRA, an employee can use it even if they decline the group plan.
  • It has a fixed annual dollar cap, set by the IRS and adjusted yearly.
  • It must be offered alongside a traditional group health plan.

What it can reimburse

  • Deductibles, copays, and coinsurance
  • Dental and vision expenses
  • Short-term, limited-duration insurance premiums
  • Other qualified excepted-benefit expenses

Who it''s for

EBHRAs suit employers who keep a group plan and want to offer a modest, flexible extra benefit — especially to employees who opt out of the group plan but still want help with dental, vision, or out-of-pocket costs. It''s a low-commitment way to broaden benefits.

The rules

To offer an EBHRA, the employer must also offer a traditional group health plan (though employees needn''t enroll in it to use the EBHRA), the benefit must stay within the annual cap, and it must be offered on a uniform basis to similarly situated employees. A broker or administrator ensures it''s set up within these constraints.

EBHRA vs integrated HRA

Both pair with a group plan, but they differ on a key point: a GCHRA requires the employee to be enrolled in the group plan, while an EBHRA can be used even by employees who decline it. The EBHRA is also capped and limited to excepted-type benefits, whereas a GCHRA focuses on the group plan''s out-of-pocket costs.

Substantiation and setup for an EBHRA

An excepted-benefit HRA still needs the basic HRA machinery: a written plan document, a way for employees to substantiate expenses, and records retained for compliance. Because it is an excepted benefit, it sits outside some ACA requirements, but it is not paperwork-free.

Common EBHRA use cases

An EBHRA shines when you want to add a modest, flexible benefit on top of other coverage.

  • Helping with dental and vision costs.
  • Covering cost-sharing like copays and deductibles.
  • Reimbursing certain short-term or excepted-benefit premiums.
  • Giving employees a little extra tax-free help without replacing their main plan.

EBHRA mistakes to avoid

A couple of errors defeat the purpose of an EBHRA.

  • Trying to use it as the employer's primary medical benefit — it cannot be.
  • Exceeding the annual IRS limit, which is adjusted each year.
  • Failing to also make a traditional group plan available to the class, which the EBHRA rules generally assume.

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Frequently asked questions

An EBHRA is a limited-dollar HRA offered alongside a group plan, capped at an annual IRS limit, that reimburses out-of-pocket costs and excepted benefits like dental and vision — and employees can use it even if they decline the group plan.

JR

Joe RosenblattFounder & ICHRA Broker, The ICHRA Broker

Joe Rosenblatt is the founder of The ICHRA Broker, an independent ICHRA brokerage that helps small businesses offer tax-free health benefits without a group plan. He works directly with employers and their advisors on ICHRA and QSEHRA setup, plan design, and compliance.

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